Zablocki Shawn Olsson Associates Mechanical Integrity Programs for MRP and SPCC MECC Kansas City May 11-13, Overland Park

1. Mechanical Integrity Programs
for RMP and SPCC
Midwest Environmental Compliance
Conference
May 11, 2016

2. Agenda
• Purpose of Mechanical Integrity Programs
• RMP
• SPCC
• Tank/Vessel testing options
• Summary

3. Purpose of Mechanical Integrity
Programs
• Ensure that the process stays as close to the
original design and installed condition as
possible by maintaining proper preventative
maintenance practices and regular inspections
• Maintaining the physical integrity of the
system and safety devices is the first line of
defense against unwanted releases

4. RMP

5. Regulatory Requirements
• EPA does NOT dictate the inspection method
or inspection frequency, they simply require
that testing be performed.
• Develop written procedures designed to
maintain the ongoing integrity of process
equipment
• Training for personnel tasked with performing
maintenance activities.

6. Regulatory Requirements
• What is covered?
– Pressure vessels and storage tanks
– Piping systems and common components such as
valves
– Relief and vent systems
– Emergency shut down systems
– Controls (monitoring devices and sensors, alarms,
interlocks, etc)
– Pumps

7. Regulatory Requirements
• Documentation shall include:
– Date of inspection/test
– Name of the person conducting the
inspection/test
– Serial # or other equipment ID
– Description of the inspection/test
– Results of the inspection/test

8. Regulatory Requirements
• Inspections and testing of process equipment
• How?
– Inspection and testing procedures should follow recognized and
accepted good engineering practices
• How Often?
– Use manufacturer’s recommendations and good engineering
practices as a baseline
– Adjust as your testing and experience dictates but document
reasons for deviations from manufacturing recommendations or
standards

9. Regulatory Requirements
• Deficiencies which are outside of acceptable
limits must be corrected before further use or
in a safe and timely manner provided that
measures have been taken to assure safe
operation
– Document all corrective action taken

10. Developing a Mechanical Integrity
Program
• Identify and categorize equipment and instrumentation to be included in
the program
– Be sure to include auxiliary systems or components,
• Determine the inspections and tests that are required to be performed on
each component
– PM activities, scheduled rebuilds, routine replacement of parts, etc
– Refer to manufacturers specifications and relevant codes and standards
• Determine the recommended testing and inspection frequencies
– Use Mfg specifications as a starting point
– May be adjusted based on your practical experience
• Outline the specific procedure required for each inspection and test.
– Identify acceptable alternatives such as which NDT methods may be used

11. Developing a Mechanical Integrity
Program
• Identify criteria for acceptable test results
• Train personnel who will be performing each test and
inspection.
– If outsourced, identify qualified contractors and ensure
they have received the proper training
• Documentation of inspection and test results
– Be sure documentation includes all elements required by
regulation – date, name of person conducting, Equipment
ID, Description of inspection or test and the results

12. Developing a Mechanical Integrity
Program
• Documentation of manufacturer’s
recommendation as to mean time to failure
– Include other sources as well such as plant
experience, codes and standards, ANSI, ASME,
ASTM, API, NFPA, etc
• Documentation to ensure that equipment
installations met quality standards and used
proper materials

13. Mechanical Integrity
Common Questions
• We utilize a computerized maintenance
system to track all PM activity, is the closed
PM in the system enough documentation to
support that the work was done?
– It depends…
• If system is very robust and contains ALL required info,
it may suffice
• Be wary of electronic pencil whipping

14. Mechanical Integrity
Common Questions
• Is it acceptable to conduct inspections/tests
less frequently than recommended by
manufacturer?
– Yes, provided you have functional data and
evidence to support

15. Mechanical Integrity
Common Questions
• I utilize contractors to perform my
maintenance activity, does that affect my
documentation needs?
– NO, The same documentation needs to be kept,
including the procedure that is followed for the
inspection/test and verification that the contract
employee performing the work has been properly
trained to do that work
– Documentation must be kept on site

16. Mechanical Integrity
Common Issues
• Regular PMs and inspections not very well
documented
• Computer generated PMs lack detail
describing tasks to be performed and
acceptable equipment conditions
• No documented basis for frequency of
inspections/tests

17. Mechanical Integrity
Common Issues
• Corrective actions not well documented if at all
• Inspections/test not performed at required
frequencies due to budget and resource
constraints
• Stretching equipment beyond its recommended
useful life without proper documentation to
show continued operation is safe
• maintenance work is contracted and contractor
retains the records

18. Mechanical Integrity
Best Practices
• Computerized maintenance systems that
generate very detailed work order for each
required inspection/test, including checklist of
procedures and tasks and indicating safe
operating conditions and limits for applicable
step/task
• Maintain hardcopy of field notes with
employee signature verifying that the work
was completed as prescribed

19. Mechanical Integrity
Best Practices
• File for each component spelling out each
activity performed on the equipment and
detailed description of findings from each
inspection, test and incident investigation
pertaining to that component. Files also
included detailed reasons for changes if any to
the frequency or type of maintenance
activities

20. Mechanical Integrity
What Does EPA Look For?
• All documentation to indicate that system
integrity is maintained properly and according to
manufacturer specs or good engineering
practices
• Physical appearance of equipment
• Training records to verify those performing
maintenance work are competent
• Documentation of PM findings and corrective
actions
• Will verify competency and frequency through
employee interviews

21. SPCC

22. Regulatory Requirements
• Test or inspect each aboveground container for
integrity on a regular schedule and whenever you
make material repairs. You must determine, in
accordance with industry standards, the
appropriate qualifications for personnel
performing tests and inspections, the frequency
and type of testing and inspections, which take
into account container size, configuration, and
design (such as containers that are: shop-built,
field-erected, skid-mounted, elevated, equipped
with a liner, double-walled, or partially buried).

23. SPCC Requirements
• Applies to bulk storage tanks
• Facility must determine appropriate testing
frequency and document that in SPCC Plan
• Regulations guide you to follow good
engineering practices and applicable codes
and standards
– STI SP001
– API

24. SPCC
• All tank testing should be documented in
report format
• Reports should identify the standard the
inspection was conducted to
• Facility should properly document that
recommendations identified in testing reports
were properly addressed

25. Options for tank testing
• Steel Tank Institute SP 001
– Applies to smaller, shop fabricated tanks
– Frequency and type of inspection determined by
tank size, containment and release detection

26. SP001 Requirements
AST Type and Size (U.S. gallons) Category 1 Category 2 Category 3
Shop-Fabricated ASTs
0-1100
(0-4164 liters)
P P P, E&L(10)
1101-5000
(4168-18,927 liters) P P, E&L(10)
[P, E&L(5), I(10)]
Or
[P, L(2), E(5)]
5001-30,000
(18,931-113,562 liters) P, E(20)
[P, E(10), I(20)]
Or
[P, E(5), L(10)]
[P, E&L(5), I(10)]
Or
[P, L(1), E(5)]
30,001-50,000
(113,566-189,271 liters)
P, E(20) P, E&L(5), I(15) P, E&L(5), I(10)
Portable Containers P P P**
P-Periodic AST inspection
E-Formal external inspection by certified inspector
I-Formal internal inspection by certified inspector
L-Leak test by owner or owner’s designee
(Yrs.)-Indicates maximum inspection interval in years
Category 1-AST’s with spill control, and with continuous release detection method
Category 2-AST’s with spill control and without continuous release detection method
Category 3- AST’s without spill control and without continuous release detection method

27. API 653
• API 653
– Applies to larger field erected tanks
– General requirements are 10 year external and 20
year internal inspections
– Schedule may be adjusted based on
recommendations of inspector
– API 653 is more stringent than SP001
– Many SPCC Plans default to API 653 which is the
more stringent standard – This is NOT necessary!

28. API 510
• API 510
– Applies to pressure vessels, regardless of size.
– Pressure vessel defined as having operating
pressure greater than 14.7 psi
– Requires 5 year external inspections and 10 year
internal inspections

29. API 570
• API 570
– Standard for piping inspections
– Requires that piping be inspected “periodically”
– Frequency of testing determined by facility owner
and/or inspector
– Generally conducted in conjunction with other
tank/vessel testing
– Primarily concerned with areas where corrosion
may be prevalent (elbows, bends, connections,
etc)

30. Summary
• RMP and SPCC do NOT indicate specific testing,
they merely require THAT testing be performed
• Regardless of regulation, the onus is on facility
owner to establish acceptable mechanical
integrity procedures
• Knowledge of the applicable codes and standards
is essential to establishing a proper, cost effective
approach
• As with anything else, documentation is key

31. Pictures

32. Insulation Damage

33. Corrosion under Insulation

34. Valve Corrosion

35. Hole in weld seam connecting pipe leg

36. Biological growth on tank shell

37. Dent on tank floor

38. Excessive bird droppings can lead to
corrosion

39. Missing Bolt on manway

40. Pit on shell wall

41. QUESTIONS??
Shawn Zablocki, P.E.
szablocki@oaconsulting.com
Office 402-938-2414 Cell 402-350-7101